Although countervailing action corresponds to a large extent with anti-dumping action as regards procedure and substance, some important differences are highlighted in this article. It is a significantly more complex instrument than antidumping action and is used relatively infrequently. Two different methods can be used to address countervailing subsidies paid by foreign governments, namely, bilateral countervailing action and multilateral dispute resolution in the World Trade Organisation (WTO). This article considers bilateral countervailing
action only, as this is all that is provided for in South African legislation and as South Africa has never pursued the multilateral route. Briefly sets out the key issues to provide an introduction to the topic, as very little has been written on countervailing action in South Africa. Such a brief article, however, cannot properly set out each of the issues pertaining
to countervailing investigations and these issues will have to be explored further in the future.